Does Quebec's Law 96 apply to a business outside Quebec?

It can. Published guidance is that the Charter reaches a business based in another Canadian province where it has clients in Quebec, offers goods or services accessible from Quebec, or communicates regularly with Quebec consumers. For a phone line the practical trigger is answering calls from Quebec customers.

Does Law 25 apply if my servers are outside Quebec?

Yes, and where the server sits does not decide the question. Law 25 governs personal information collected in the course of an enterprise in Quebec, with no headcount threshold and no requirement that the business be Quebec-based. If anything a server elsewhere adds an obligation rather than removing one, because the assessment duty is triggered by information leaving Quebec.

Do I have to store Quebec customer data in Quebec?

No. The obligation is to assess the transfer before it happens, not to avoid it: you have to establish that the information will receive adequate protection where it is going, and a communication outside Quebec also has to be covered by a written agreement. Storing outside Quebec without doing that is the failure, not storing outside Quebec.

Does every employee have to speak French?

No. The duty is that service is offered in French, not that each person on staff speaks it. For a phone line that means a French greeting, a French menu and French announcements, with another language offered from there.

Do I need a Quebec company to serve Quebec customers?

No. Neither statute requires a Quebec entity, and incorporating elsewhere does not put you outside them. What you do need is the same short list any Quebec-serving business needs: service in French, a named person responsible for personal information with published contact details, an assessment before information leaves Quebec, and a register of confidentiality incidents.

Blog

Serving Quebec from outside: Law 25 and 96

Both statutes can apply to a business based in another province. Having Quebec customers is usually enough. Being incorporated elsewhere is not a shield.

John · Owner and CEO · 3 min read · August 19, 2026 · updated September 6, 2026

A business based in Ontario, Alberta or the United States can still fall under Quebec's Law 25 and Law 96. Law 96 can reach a company that has Quebec clients or offers services accessible from Quebec; Law 25 attaches to the collection of personal information about people in Quebec. Incorporating elsewhere does not decide the question.

If you answer calls from Quebec, this is worth ten minutes.

Does Law 96 reach a business based outside Quebec?

It can. Published guidance is that the Charter can apply if your business is based in another Canadian province and any of the following holds: you have clients in Quebec, you offer goods or services accessible from Quebec (in person or online), or you communicate regularly with Quebec consumers.

Two columns comparing what does not decide whether Law 25 and Law 96 apply with what does — Where you are incorporated, where your server sits, your headcount and your area code decide nothing; having Quebec customers decides it.
Reuse this figure anywhere, including commercially, with credit to Ringfully and a link back to this page. CC BY 4.0.

For a phone line the practical trigger is having a number Quebec customers call, or serving Quebec customers on any number.

What follows if it applies: service offered in French, which for telephone means the greeting, the menu, and the announcements around them. Law 96 and your phone system covers the shape.

Does Law 25 reach one?

It can, and where your server sits does not decide the question. Law 25 governs personal information collected in the course of business in Quebec, with no headcount threshold and no Quebec-entity requirement, and a server outside the province does not exempt you: if anything it does the opposite, because the transfer obligation is triggered by information leaving Quebec.

So an out-of-province business serving Quebec customers can find itself both subject to the statute and performing exactly the cross-border communication the statute asks it to assess first. Where your call data lives covers that assessment.

The realistic list for a phone line

If you take calls from Quebec:

the greeting is in French, with a brief offer of another language
recording announcements are in French, and name a purpose
someone is named as responsible for personal information, with contact details published
an impact assessment exists before Quebec personal information is stored outside Quebec
a register of confidentiality incidents exists, covering call records

None requires a Quebec entity. All require a decision.

What does not follow

A few things worth not concluding:

It does not mean you must store data in Quebec. The obligation is to assess the transfer, not avoid it.
It does not mean every employee must speak French. It means service is offered in French.
It does not scale only with headcount. The 25-employee threshold governs OQLF registration and francization, not the underlying duty to serve in French.

Where Ringfully is

We are not yet incorporated, which is stated on every policy page rather than implied, and our data is in AWS us-east-1 in the United States. Neither fact exempts a Quebec-serving customer from anything above, and both are the sort of thing you should be able to establish about a vendor without asking.

Our sub-processor list is published in full, with no form and no login, naming each party and what it receives, and the gaps that go with it are on security.

A description of what the statutes ask, not legal advice. Whether either applies to your business is a fact-specific question for a Quebec-qualified adviser, and cheaper to answer before you start than after.

Questions people ask

Does Quebec's Law 96 apply to a business outside Quebec?: It can. Published guidance is that the Charter reaches a business based in another Canadian province where it has clients in Quebec, offers goods or services accessible from Quebec, or communicates regularly with Quebec consumers. For a phone line the practical trigger is answering calls from Quebec customers.
Does Law 25 apply if my servers are outside Quebec?: Yes, and where the server sits does not decide the question. Law 25 governs personal information collected in the course of an enterprise in Quebec, with no headcount threshold and no requirement that the business be Quebec-based. If anything a server elsewhere adds an obligation rather than removing one, because the assessment duty is triggered by information leaving Quebec.
Do I have to store Quebec customer data in Quebec?: No. The obligation is to assess the transfer before it happens, not to avoid it: you have to establish that the information will receive adequate protection where it is going, and a communication outside Quebec also has to be covered by a written agreement. Storing outside Quebec without doing that is the failure, not storing outside Quebec.
Does every employee have to speak French?: No. The duty is that service is offered in French, not that each person on staff speaks it. For a phone line that means a French greeting, a French menu and French announcements, with another language offered from there.
Do I need a Quebec company to serve Quebec customers?: No. Neither statute requires a Quebec entity, and incorporating elsewhere does not put you outside them. What you do need is the same short list any Quebec-serving business needs: service in French, a named person responsible for personal information with published contact details, an assessment before information leaves Quebec, and a register of confidentiality incidents.

About the author

John

Owner and CEO

Owner and CEO with over 10 years of experience in the IT industry, including more than 5 years specializing in VoIP and cloud communications. Experienced in designing, deploying, and supporting reliable communication solutions for businesses.

Keep reading

If you are working out what Law 25 or Law 96 asks of your phone line, tell us what you record and who you serve, and we will say what we handle and what stays your job.

Talk to us